News & Analysis as of

Securities Regulation › Incident Response Plans

Morgan Lewis

Key Cybersecurity, Privacy, and National Security Considerations for Data Centers in 2025

Morgan Lewis on

Unlike Europe’s comprehensive General Data Protection Regulation framework, the United States still lacks an all-encompassing data privacy statute. Instead, data centers operating in the United States must navigate a complex...more

SEC Compliance Consultants, Inc. (SEC³)

Lessons From 2024: Tips for Private Fund Managers

SEC Compliance Consultants, Inc. (SEC³) on

As we look back on the SEC’s actions in 2024, we wanted to share our thoughts on lessons learned that we believe will carry through to 2025....more

Robinson+Cole Data Privacy + Security Insider

Four Companies Settle Allegations of Deceptive Cyber Disclosures with SEC

Robinson+Cole Data Privacy + Security Insider on

This week, the Securities and Exchange Commission (SEC) charged four public companies for alleged deceptive cyber disclosures: Unisys Corp., Avaya Holdings Corp., Check Point Software Technologies Ltd., and Mimecast Limited....more

Troutman Pepper Locke

Cyber Incident Response Checklist for SEC Compliance

Troutman Pepper Locke on

By now, public companies are generally aware of the cybersecurity rules adopted by the U.S. Securities and Exchange Commission a year ago, requiring public companies to disclose material cybersecurity incidents under Item...more

Carlton Fields

Going Up: SEC Cyber Incident Reporting - Regulation S-P Amendments Take It to Next Level

Carlton Fields on

On May 16, 2024, the SEC breathed new life into its decades-old Regulation S-P, which requires firms to adopt policies and procedures for the protection of customer information and records. The amended rule balloons the...more

Troutman Pepper Locke

SEC Cybersecurity Incidents Disclosures: Materiality, Decryptors, and Ransom Payments - Dear Mary – Incidents + Investigations...

Troutman Pepper Locke on

I work for a public company that recently experienced a ransomware attack. Fortunately, we were able to restore our business operations quickly by obtaining a decryption key from the threat actor. Given that we managed to get...more

Akin Gump Strauss Hauer & Feld LLP

Fund Managers Must Assess Whether Microsoft/CrowdStrike Outage Has Triggered Additional Regulatory Filings

Akin Gump Strauss Hauer & Feld LLP on

A global technology outage linked to the cybersecurity firm CrowdStrike crashed Microsoft apps and triggered major disruptions across the asset management sector, along with other global industries. Private fund managers...more

Bass, Berry & Sims PLC

Just In! More Guidance on Material Cybersecurity Incidents (Item 1.05 of Form 8-K)

Bass, Berry & Sims PLC on

On June 24, the Securities and Exchange Commission (SEC) released five additional Compliance and Disclosure Interpretations for Item 1.05 of Form 8-K (Material Cybersecurity Incidents). These interpretations provide...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for May 2024

SEC Compliance Consultants, Inc. (SEC³) on

SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...more

Hinckley Allen

Final Amendments to Regulation S-P under Securities Exchange Act of 1934

Hinckley Allen on

On May 15, 2024, the Securities and Exchange Commission (the “SEC”) issued final amendments (the “Amendments”) to Regulation S-P (originally adopted in 2000), which governs the treatment of a customer’s nonpublic personal...more

Keating Muething & Klekamp PLL

Proposed SEC Cybersecurity Rules

Keating Muething & Klekamp PLL on

On March 9, 2022, the Securities and Exchange Commission (“SEC”) proposed amendments to rules to expand and standardize disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by...more

BakerHostetler

The SEC OCIE Announces Increased Scrutiny of Broker-Dealers’ and Investment Advisers’ Cybersecurity Programs

BakerHostetler on

On September 15, 2015, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert (2015 Risk Alert) to provide broker-dealers and investment...more

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